PRUDENTIAL'S SINCERITY EFFORT SINKS LIKE A ROCK

One: Depending on how the federal and state investigations turn out, the entire firm could yet be indicted.

Two: For Prudential Securities, after agreeing to pay $330 million in civil penalties to allegedly defrauded investors, this is no time for high-gloss bombast designed to deflect the ugly reality.

Three: But there's always gritty "straight talk" designed to deflect the ugly reality.

Whether or not Prudential illegally sold ramshackle tax shelters to 340,000 unwitting limited partners, the allegations (and third-of-a-billion-dollar piece of the rock in settlement) have sullied the firm's reputation. Hence the rough-hewn look of a new TV and print campaign from Deutsch/Dworin, New York, which won the $20 million account just in time to see its client publicly disgraced.

"One: It's my job to set the tone for this company," says a gritty, b&w Wick Simmons, Prudential ceo, to open one spot. It's all very hand-held, in-and-out of focus, low depth of field. If the cinema were any more conspicuously primitive, it would be a zoetrope. Thus, in the spirit of such affected unslickness, Simmons glances back and forth from his handwritten list of items to the camera.

"Two: To me that means being direct, being truthful. We call that straight talk.

"Three: Straight talk means being on the phone when there's news, good or bad.

"Four: I'm straight with people and I expect the same, from our brokers to my kids.

"Five: Time is money. Thank you for your time."

Six: Why is this guy quite looking us not quite in the eye? Seven: Why does he have to consult notes to convey "direct" and "truthful"? Eight: When he says, "Thank you for your time," as do a couple of his broker employees in the other two spots of this campaign, stiffly and monotonously, why do they sound so much like the fictitious protodweeb Frank Bartles thanking us for our support?

There's no faulting Deutsch for its strategy of trying to humanize Prudential Securities. Better to portray the firm as a family of uninspiring equities wonks than a conspiracy of Gucci-shod swindlers. And references in two of the spots to the children of the employees inject just the right note of humanity. The rest, however, is overkill.

In its zeal to depict straightforward, down-to-earth professionalism, the agency has delivered three TV clods from hell. No doubt they are three accomplished gentlemen of the highest integrity, but they do not communicate forthrightness. They communicate fake forthrightness. They communicate "We are so worried about our reputation, we are prepared to pretend we are the least sophisticated bunch of boobs on Wall Street." Verite? No. It is manifestly disingenuous. Worst of the bunch is Simmons himself, who comes off as nothing less than shifty.

Certainly many viewers will be charmed, and gulled, by the ostentatious humility of the campaign. But the most important audience, retail investors, will see the coyness for what it is. Indeed, those familiar with Prudential's predicament are apt to see the theme, "It starts with straight talk," and take it to its logical conclusion: